Form Locators 39-41: Structure and Placement of Value Codes
Value Codes are two-digit alphanumeric identifiers used on institutional claims to report specific monetary amounts or quantitative data required for claim processing. On the physical UB-04 (CMS-1450) claim form, these codes are reported in Form Locators (FL) 39, 40, and 41.
Each of these form locators contains four lines (labeled a, b, c, and d), allowing for a total of 12 value codes to be reported on a single paper claim. Each line is divided into two distinct columns: the "Code" column for the two-character value code, and the "Amount" column for the corresponding numerical value.
The Amount column must be formatted correctly to prevent immediate rejection by the clearinghouse or payer. When reporting monetary amounts, the value must be right-justified and include dollars and cents. The cents must be entered in the dedicated cents column. When reporting quantitative counts—such as pints of blood or inpatient days—the number is entered as a whole number in the dollars portion of the field, and the cents portion must be populated with two zeros (00).
For electronic billing using the ANSI 837I format, value codes are mapped to Loop 2300, Segment HI (Value Information). The segment utilizes the BE qualifier to indicate a value code. Unlike the paper form's 12-code limit, the 837I format allows institutional billers to report up to 36 value codes per claim, accommodating complex inpatient stays with multiple primary payer payments, deductibles, and day counts.
Medicare Secondary Payer (MSP) Value Codes
Institutional billers must utilize specific value codes to report primary payer payments when Medicare is the secondary payer. The Medicare Secondary Payer (MSP) value codes dictate exactly how much the primary insurance paid, which the Medicare Administrative Contractor (MAC) uses to calculate the secondary payment.
The core MSP value codes correspond directly to the reason the primary payer is liable. Value Code 12 is used for Working Aged beneficiaries, Value Code 13 for End-Stage Renal Disease (ESRD) coordination periods, Value Code 14 for Auto/No-Fault insurance, Value Code 15 for Workers' Compensation, and Value Code 43 for Disabled beneficiaries.
When billing an MSP claim, the amount entered next to the applicable value code must match the exact payment amount listed on the primary payer's remittance advice. If the primary payer applied the entire allowed amount to the patient's deductible, the primary payment is zero. In this scenario, billers must report the appropriate MSP value code with an amount of $0.00.
MSP value codes must also align with the Condition Codes reported in FL 18-28. For example, if Condition Code 02 (Condition is Employment Related) is present, MACs like Noridian and National Government Services (NGS) expect to see Value Code 15 (Workers' Compensation) populated. Failure to link the correct condition code with the corresponding MSP value code will result in the claim being Returned to Provider (RTP) via the Fiscal Intermediary Standard System (FISS).
Inpatient Days and Accommodation Value Codes
For inpatient facility claims (Type of Bill 11X), value codes are mandatory for reporting patient days. The MAC relies on these codes to track beneficiary utilization against their Medicare Part A benefit periods.
The primary day-count codes are Value Code 80 (Covered Days), Value Code 81 (Non-Covered Days), Value Code 82 (Co-insurance Days), and Value Code 83 (Lifetime Reserve Days).
A strict balancing rule applies to inpatient day reporting: the sum of the days reported in Value Code 80 and Value Code 81 must exactly equal the total number of days spanning the Statement Covers Period reported in FL 6 (From and Through dates). When calculating these days, billers must apply the midnight rule. The day of admission is counted as a day, but the day of discharge is not, unless the patient was admitted and discharged on the exact same date.
If a patient exhausts their regular Medicare Part A days during a stay and elects to use their lifetime reserve days, the biller must report the total covered days in Value Code 80, and simultaneously report the subset of those days that are lifetime reserve days using Value Code 83.
MACs enforce strict edits on day counts. If the days reported in FL 39-41 do not mathematically align with the dates of service in FL 6, the claim will trigger Reason Code 31031 (Out of Balance Days) and be sent to the RTP file for correction.
Blood Deductibles and Hemophilia Value Codes
Billing for blood and blood products requires precise coordination between revenue codes and value codes to satisfy the Medicare Part A and Part B blood deductibles. Medicare requires beneficiaries to pay for or replace the first three pints of whole blood or packed red cells per calendar year.
To report blood deductible data, billers use a specific subset of value codes. Value Code 06 (Medicare Blood Deductible) is used to report the monetary amount the facility is charging for the unreplaced pints of blood that fall under the deductible. The amount field for VC 06 must contain a dollar value, not a pint count.
Conversely, Value Code 37 (Pints of Blood Furnished) requires a quantitative count. The amount field must reflect the exact number of pints administered to the patient. Value Code 38 (Blood Deductible Pints) reports the number of unreplaced pints applied to the patient's three-pint deductible, while Value Code 39 (Pints of Blood Replaced) reports the number of pints the patient or a donor replaced.
If a facility reports Revenue Code 038X (Blood) on the claim, the MAC system will automatically look for Value Code 37. If VC 37 is missing, or if the pints reported in VC 38 and VC 39 exceed the total pints furnished in VC 37, the claim will fail validation edits and reject before reaching the adjudication phase.
Comprehensive Reference Table of Common UB-04 Value Codes
The National Uniform Billing Committee (NUBC) maintains the official code set for FL 39-41. Below is a reference table of the most frequently used value codes in institutional revenue cycle management, categorized by their required amount format (Monetary vs. Count).
| Value Code | Description | Amount Field Format |
|---|---|---|
| 01 | Most Common Semi-Private Rate | Monetary |
| 02 | Hospital Has No Semi-Private Rooms | Monetary ($0.00) |
| 06 | Medicare Blood Deductible | Monetary |
| 12 | Working Aged Beneficiary/Spouse (MSP) | Monetary |
| 13 | ESRD Beneficiary (MSP) | Monetary |
| 14 | Auto/No-Fault Insurance (MSP) | Monetary |
| 15 | Workers' Compensation (MSP) | Monetary |
| 16 | PHS or Other Federal Agency (MSP) | Monetary |
| 31 | Patient Liability Amount | Monetary |
| 37 | Pints of Blood Furnished | Count (Whole Number) |
| 38 | Blood Deductible Pints | Count (Whole Number) |
| 39 | Pints of Blood Replaced | Count (Whole Number) |
| 43 | Disabled Beneficiary Under Age 65 (MSP) | Monetary |
| 44 | Amount Provider Agreed to Accept as Payment in Full | Monetary |
| 47 | Any Liability Insurance (MSP) | Monetary |
| 50 | Physical Therapy Visits | Count (Whole Number) |
| 54 | Newborn Birth Weight in Grams | Count (Whole Number) |
| 61 | Place of Residence where Service is Furnished | MSA/CBSA Code |
| 80 | Covered Days | Count (Whole Number) |
| 81 | Non-Covered Days | Count (Whole Number) |
| 82 | Co-insurance Days | Count (Whole Number) |
| 83 | Lifetime Reserve Days | Count (Whole Number) |
When entering count-based codes (like 37, 50, 54, or 80-83) in the 837I format, ensure the clearinghouse software does not erroneously append decimal points that could convert "5 days" into "0.05 days" in the EDI transmission.
Resolving Value Code Claim Denials and RTPs
Value code errors typically result in front-end rejections or Return to Provider (RTP) statuses rather than formal denials, because the claim lacks the structural integrity required for adjudication.
When a claim is rejected on the 835 Electronic Remittance Advice (ERA) for value code issues, it frequently presents with Claim Adjustment Reason Code (CARC) 16 (Claim/service lacks information or has submission/billing error(s)) paired with Remittance Advice Remark Code (RARC) MA130 (Your claim contains incomplete and/or invalid information, and no appeal rights are afforded because the claim is unprocessable).
In the FISS DDE system, billers will encounter specific Reason Codes. Reason Code 31381 indicates a missing or invalid value code. This usually occurs when a related field triggers a requirement. For example, if FL 31-34 contains Occurrence Code 24 (Date Insurance Denied), the system expects a corresponding MSP value code with a $0.00 amount to indicate the primary payer processed but did not pay the claim.
To resolve these errors, revenue cycle staff must audit the cross-dependencies on the UB-04. Verify that all Condition Codes (FL 18-28) and Occurrence Codes (FL 31-34) have their mandatory Value Code counterparts. For MSP claims, pull the primary EOB and verify that the payment amount exactly matches the monetary value reported in FL 39-41. For inpatient claims, recalculate the admission and discharge dates against the sum of Value Codes 80 and 81.
Frequently Asked Questions
Q: How do I report a zero-dollar amount for a value code? A: If a value code requires a zero-dollar amount (such as an MSP value code when the primary payer applied the entire balance to the deductible), enter the two-digit code in the Code column and "0.00" in the Amount column. Do not leave the Amount column blank if the code is present.
Q: What is the difference between Value Code 81 and the non-covered days field in FL 7? A: FL 7 is a dedicated box for total non-covered days, while Value Code 81 is the specific code used in FL 39-41 to report those same non-covered days. Both must be populated on an inpatient claim, and the numerical values in FL 7 and VC 81 must match exactly.
Q: Can I report the same value code more than once on a single UB-04? A: Generally, no. You cannot list Value Code 12 twice on the same claim. If there are multiple payments from the same type of primary payer, you must aggregate the monetary amounts and report the total sum under a single instance of the value code.
Q: How are fractional days reported in Value Codes 80-83? A: Fractional days are never reported. Inpatient days are calculated as whole numbers based on the midnight rule. A patient is either in the facility at midnight (1 day) or they are not.
Q: What happens if I run out of space in FL 39-41 on a paper claim? A: If you exceed the 12 available slots on a paper UB-04, you must use an attachment to report the additional codes. However, paper claims are extremely rare. The electronic 837I format allows up to 36 value codes in Loop 2300, which is sufficient for virtually all complex institutional billing scenarios.
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